Sarah Roberts*, Oak Ridge Associated Universities ; Edward Regnier, U.S. Department of Energy; Tim Vitkus, Oak Ridge Associated Universities; Alexander Williams, U.S. Department of Energy
Abstract: Recent rulemaking by the U.S. Department of Energy (DOE) has formalized the requirements for independent verification (IV) of both real and personal property at DOE and National Nuclear Security Administration (NNSA) sites. DOE Order 458.1, Radiation Protection of the Public and the Environment, provides a more detailed framework for radiological clearance and IV than its predecessor DOE Order 5400.5, and emphasizes application of the “graded approach” for property clearance. The Order also incorporates recommendations for property release methodologies including the well-known Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) and the more recently issued guidance document for the release of materials and equipment (the Multi-Agency Radiation Survey and Assessments of Materials and Equipment Manual or MARSAME). The new Order has resulted in many discussions related to the application of requirements at both the headquarters and field site levels. This is not completely unexpected given that one of the major objectives of the document, to allow for a graded approach, allows for flexibility in application. There are trends in lessons learned that should be considered when evaluating the applicability of IV requirements in the Order. Some of those lessons learned include the reduction of overall project risk by early engagement of IV personnel (prior to commencement of the final status surveys), consideration of verification requirements prior to backfilling excavated (remediated) areas, and interpretation of the gray area for what constitutes a “graded approach”.
